Privacy Statement

Docal Ltd., t/a DFP Pension & Investment Consultants (hereinafter ‘DFP’) is committed to protecting and respecting your privacy. It is the intention of this privacy statement to explain to you the information practices of DFP in relation to the information we collect about you.

Please read this statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Who are we?

The DFP Group, with offices in Dundalk and Dublin, are a financial advisory firm operating in the Irish market, specialising in the area of advice regarding pensions and investments.

As a business, we pride ourselves on the expertise and reputation we have established over the years.

DFP offers a broad range of services to clients, specialising in Pre and Post Retirement planning. Our sister company Platinum Pensioneer Trustees Ltd, is a Revenue approved Trustee which allows us to establish Small Self-Administered Pension Schemes and act as a Corporate Trustee.

Purpose for processing your data

DFP will treat all personal information given to us as confidential information and we will not disclose such information except as permitted by you or as required by law. The personal data you provide us will be held on paper and electronically and will only be used for the purposes permitted under relevant Data Protection law.

We will process any personal data you provide us for the following reasons:

To contact you in relation to our services.

To provide you with information regarding our main financial and ancillary services offered by us or any of our sister companies.

To respond to any queries you submit to us.

To send you newsletters or other forms of communication in relation to services and products.

Where you have consented to sharing of your information with third parties we will permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by post, email or telephone.

Why do DFP need to collect and store personal data?

In order for us to provide you with financial advicewe need to collect personal data for processing of policies of insurance or any other related financial service we may offer to provide for you within our authorisation remit. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

In terms of being contacted for marketing purposes, DFPwould contact you separately for additional consent.

How will DFP use the personal data it collects about me?

DFP will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.

DFP is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances willDFP contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Why we are processing your data? Our legal basis:

Our reason and purpose for processing your personal data is one of the following:

We need to process your data to complete the performance of a contract where you, the data subject is a party ..DFP processes data without consent in order to fulfil contractual obligations [such as bank details to process salaries, postal address in order to supply products and services, etc.].

Legal obligation

Protect the vital interests of the data subject, including the protection of rights and freedoms

Processing that is in the public interest

Necessary for the legitimate interests of the data controller or third party, unless the processing is overridden by the vital interests, including rights and freedoms

National law

Special Categories of Personal Data

If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethic origin – financial information is not classified as special categories of personal data) – we will ensure the below:

we will obtain your explicit consent

the personal data is necessary for employment rights or obligations;

protect the vital interests of the data subject, including the protection of rights and freedoms;

necessary for the legitimate activities with appropriate safeguards;

personal data made public by the data subject;

legal claims;

substantial public interest;

preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, provision of health or social care treatment, or management of health and social care systems and services, under the basis that appropriate contracts with health professionals and safeguards are in place;

public health, ensuring appropriate safeguards are in place for the protection of rights and freedoms of the data subject, or professional secrecy;

national laws in terms of processing genetic, biometric or health data.

Who are we sharing your data with?

We may pass your personal data on to third-party service providers contracted to DFP in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfill the service they provide on your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with DFP’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise

If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards and on condition that enforceable data subject rights and effective legal remedies for you the data subject are available.

Data Subjects Rights:

We, DFP facilitate the data subject’s rights in line with the data protection policy and the subject access request procedure. This is available on request.

Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you.

Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records.

Right to restriction of processing – where certain conditions apply, you have a right to restrict the processing.

Right of portability – you have the right to have the data we hold about you transferred to another organisation.

Right to object – you have the right to object to certain types of processing such as direct marketing.

Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

Right to judicial review: in the event that Organisation Name refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.

Additional information we are providing you with to ensure we are transparent and fair with our processing

Retention of your personal data

Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. DFP will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body The Central Bank of Ireland and our internal governance.

Withdraw consent

If we are relying on your consent to process your data you can withdraw this at any time – this does not affect the lawfulness of processing based on your consent before its withdrawal.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by DFP (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and DFP’s data protection representatives Data Protection Officer.

Failure to provide further information if need see Art 12(e)

If we are collecting your data for a statutory requirement (payroll) or to fulfill a contract (life policy or insurance policy) and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.

Profiling – automatic decision making

The GDPR gives data subjects the right to avoid being “subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.”

GDPR clarifies that the decision itself may, nonetheless, be made provided it is:

necessary for entering into, or performance of, a contract between the data subject and a data controller;

authorised by Union or member state law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; such safeguards may include anonymisation or pseudonymisation; or

based on the data subject’s explicit consent.

Additional Processing

If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information prior to processing this data.

If we have received your personal data from another source:

DFP is committed to protecting and respecting your privacy.

It is the intention of this privacy statement (“Privacy Statement”) to explain to you the information practices of DFP in relation to the information we collect about you and other users.

We want to share any other information required to demonstrate that the processing is fair and transparent.

If we have received your personal data from another source we will endeavour to share with you:

one month of obtaining the personal data, in accordance with the specific circumstances of the processing;

at the first instance of communicating in circumstances where the personal data is used to communicate with the data subject;

when personal data is first disclosed in circumstances where the personal data is disclosed to another recipient.

The above will not apply if:

You already have the information;

The provision of the above information proves impossible or would involve an excessive effort

Obtaining or disclosure of personal data is expressly identified by Member State law; or

Personal data must remain confidential subject to an obligation of professional secrecy regulated by Member State law, including a statutory obligation of secrecy.

Responsibilities

The Data Protection Officer is responsible for ensuring that the privacy notice(s) is correct and that mechanisms exist such as having the Privacy Notice(s) on DFP’s website to make all data subjects aware of the contents of this notice prior to DFP commencing collection of their data.

All staff that need to collect personal data are required to follow this procedure.

Questions Regarding the Privacy Statement and Conditions of Use

If you have any questions about our Privacy Statement and Conditions of Use, or any concern about privacy or the use of this Site in general, please contact us by e-mail at info@edfp.ie

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.